ML16291A019

OPPD Pre-Submittal Meeting Regarding Fort Calhoun Station Decommissioning October 18, 2016

ML16291A019
Person / Time
Site:	Fort Calhoun
Issue date:	10/17/2016
From:	Omaha Public Power District
To:	Lyon C Plant Licensing Branch IV
Lyon C, NRR-DORL 415-2296
References
TAC MF8114
Download: ML16291A019 (14)

Text

Omaha Public Power District (OPPD)

Fort Calhoun Station (FCS) Decommissioning October 18, 2016

FCS Decommissioning Team

• Mary Fisher - Sr. Dir. FCS Decommissioning

• Brad Blome - Mgr. Site Regulatory Assurance

• Herb Childs - Mgr. Site Security

• Ted Maine - Mgr. Radiation Protection

• Tim Uehling - Mgr. Site Training Also present: David Daigle - ENERCON, Emergency Preparedness Specialist 2

Background

• OPPD is a publicly-owned electric utility and is a political subdivision of the state of Nebraska

• Governed by a publicly elected Board of Directors

• On 5/12/16, OPPD management recommended ceasing FCS operations to the Board of Directors

• On 6/16/16, OPPD Board of Directors voted and approved ceasing FCS operations and going to SAFSTOR 3

Initial NRC Submittals

• Initial certification to Permanently Cease Operations by 12/31/16 submitted on 6/24/16

• Updated certification submitted on 8/25/16, FCS will Permanently Cease Operations on 10/24/16

• Certification of Permanent Removal of Fuel from the Reactor Vessel will be submitted in November 2016 4

Decommissioning Approach

• Multidisciplinary teams supplemented with several vendors with decommissioning experience

• Benchmarking Trips to Crystal River, Vermont Yankee, Zion, Kewaunee; future trips planned

• Industry decommissioning groups Nuclear Energy Institute (NEI) Decommissioning Transition Team Industry Regulatory Assurance (RA) Decommissioning Users Group Emergency Planning Decommissioning Users Group

• Decommissioning Oversight Committee 5

Key SAFSTOR Decision Points

• Decommissioning Funds

• Possible Decommissioning Services Agreement fourth quarter 2016

• Independent Spent Fuel Storage Installation (ISFSI) timeline and vendor selection for additional casks second quarter 2017

• Evaluate SAFSTOR/DECON timelines 6

Fort Calhoun SAFSTOR Timeline End Zirc SHUTDOWN All Fire Period Oct 24, 2016 Rev 1 17 months Spent Fuel 10/13/16 On ISFSI Decom Decom Decom Decom ONLINE cost cost cost cost Plant in Update Update Update Update SAFSTOR to to to to NRC NRC NRC NRC Decom Submit Letter(s) ISFSI cost

- Cease Operations Campaign Update

- Permanent Defueled PSDAR/DCE ISFSI Only to Submittal

~03/31/17 PDTS Tech Specs NRC Issued Issued 3Q16 4Q16 1Q17 2Q17 3Q17 4Q17 1Q18 2Q18 3Q18 4Q18 1Q19 2Q19 3Q19 4Q19 1Q20 2Q20 3Q20 4Q20 1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23 YEAR 2016 2017 2018 2019 2020 2021 2022 2023 Staffing Adjustments Decon Decon Safstor Safstor Change MGMT Change MGMT Trans to ORGANIZATION Transition to Plans-develop Plans-Implement SAFSTOR (1)

CHANGES SAFSTOR (2)

Decision Milestone SAFSTOR/DECON Prepare/submit ISFSI NRC review ISFSI Prepare/ NRC Review PDTS Submit PDTS Only Tech Specs Only Tech Specs Tech Specs ODCM Prepare/issue ODCM Prepare/issue ODCM Milestone Review SAFSTOR/DECON Chapter 14 USAR update Remaining USAR Update USAR Update USAR Update USAR and Accident Analysis FHA Analysis System System Reclassification System Reclassification Post MODs Systems Drain/

Eval/Recategorize Energy Removal (Avail/Abandon)

(No Spent Fuel in Pool)

System Systems Drain/ Sec Sys Abandonment Energy Removal Isolation/draining (Avail/Abandon)

SFP Sys Pri Sys Abandonment Abandon and abandonment NRC Approval of PSEP Revise ERO Plan EMERGENCY (PSEP/PDEP) ERO Plan NRC Approval of PDEP and exemption Request PDEP/no offsite staff or facilities PLANNING (ISFSI ONLY)

Maintain Cybersecurity Plan Revise Security Plan NRC Review of Security Plan Revise Security Plan NRC Review of Security Plan SECURITY PLAN (Defueled) Exemption request (ISFSI ONLY) Exemption request Station procedure reviews/revisions/deletions Legend:

Determine Engineering Programs DCE - Decommissioning Cost Estimate Developed by Transition Team Review Fire Brigade ERO - Emergency Response Organization ENG/PROGRAMS required/not required Staffing Adjustments FHA - Fuel Handling Analysis Note: Represents our best knowledge Revise Fire Hazard ISFSI - Independent Spent Fuel Storage Installation as of this revision. This plan will be Analysis ODCM - Offsite Dose Calculation Manual updated as new information dictates.

Engineering Develop ECs for MODs HE-2 Aux Bldg Crane MOD PDEP - Permanently Defueled E-Plan PSDAR - Post Shutdown Decommissioning Activities Report Developed by DECOM Team MODIFICATIONS Evaluate SFP Install SFP Cooling MOD Cooling MOD PSEP - Post Shutdown E-Plan Note: This Color Graphic is a PDTS - Permanently Defueled Tech Specs communication tool only. It is not a SFP Indication MOD Heating/cooling footprint reduction SFP - Spent Fuel Pool controlled document or schedule and Electrical footprint reduction USAR - Updated Safety Analysis Report subject to change.

3Q16 4Q16 1Q17 2Q17 3Q17 4Q17 1Q18 2Q18 3Q18 4Q18 1Q19 2Q19 3Q19 4Q19 1Q20 2Q20 3Q20 4Q20 1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23

Emergency Plan Changes Post Shutdown EPlan

• Submitted 9/2/16

• Revised on-shift and Emergency Response Organization (ERO) staffing based on analysis of required post-shutdown ERO positions but does not change any Emergency Action Level (EALs)

• Meeting with all supporting offsite agencies held on 9/8/16; additional meetings are scheduled

• Verification drills including offsite agencies scheduled for first quarter 2017 8

Emergency Plan Changes Supporting submittals

• Certified Fuel Handler (CFH) Training Program submitted on 7/7/16

• One Request for Additional Information (RAI) received; response provided 10/7/16

• Technical Specifications (TS), Section 5, Administrative Controls, License Amendment Request (LAR) submitted 9/28/16

• Severe Weather Security Plan Exemption Request (10CFR73.55) submitted 10/7/16 9

Emergency Plan Changes Permanently Defueled EPlan

• Revises EALs, removes all offsite ERO functions and significantly reduces ERO staffing

• Initial draft prepared and undergoing cross-disciplinary team & offsite agency reviews

• Supporting vendor analyses: Zirconium Fire, Shine, Radiation Monitor Set Points and updated Fuel Handling Accident Boundary Dose

• Permanently Defueled EPlan and associated Exemption Requests (10CFR50.47 & App E) will be submitted December 2016 10

Other Submittal Plans

• NRC fee reclassification in November 2016

• Exemption for Maintenance of Records in December 2016

• SAFSTOR Security submittal in December 2016

• Post Shutdown Decommissioning Activities Report (PSDAR), Decommissioning Cost Estimate (DCE),

Spent Fuel Management plan and Limited Site Characterization in first quarter 2017

• Permanently Defueled TS LAR in first quarter 2017

• Insurance Exemption requests in first quarter 2017

• Quality Assurance Topical Report update in first quarter 2017 11

Other Submittal Plans Fukushima

• Letter submitted to NRC on 8/12/16 for relaxation of implementation date for compliance with Order EA-12-049 (Mitigation Strategies for Beyond Design Basis External Events) to 8/31/17

• Request to rescind Order EA-12-051 (Reliable Spent Fuel Pool Instruments) submitted 9/9/16

• Updated Overall Integrated Plan (OIP) for EA12049 by 10/31/16

• Certify compliance with EA-12-049 by 8/31/17 12

Other Submittal Plans Confirmatory Action Letter (CAL) items

• Submit LAR for Class 1 Structures (Auxiliary Building) needed to support decommissioning in October 2016

• Submit letter to request closure of NRC CAL items in October 2016 National Fire Protection Association (NFPA) 805

• LAR to delete Fire Protection License Condition and utilize NFPA 805 Decommissioning Fire Program in December 2016 CyberSecurity

• Applicable CyberSecurity submittals based on proposed NRC guidance planned in first quarter 2017 13

FCS Decommissioning Closing Comments/Questions 14